Taxpayers and authorities are alive to the calls for greater transparency. And though this is building public pressure on tax authorities to milk multinational cash cows for all they can get, there is a growing realisation among authorities that ill-designed international tax rules and strains on resources, as well as the complex manner in which multinationals arrange their tax affairs, means that working with – rather than against – the largest taxpayers is the best way forward.
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Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief